Public Hearing to Consider Proposed Amendments to the
Commercial Harbor Craft Regulation (chc2021)
On behalf of
more than 1,000 petition signatories (names attached at the end of
this letter) who reside, work and travel to and from Catalina
Island, this letter registers deep concerns over CARB’s
current proposed harbor craft rules.
The past few years have created hardships for many
localities, especially those made up of small businesses and
tourism, CARB’s proposed regulations could negatively impact
the ability of Catalina Channel Express (CCE) and other passenger
ferry services to continue operations; the vital ferry
transportation systems that transport passengers to and from the
Island. CARB’s proposed rules will require CCE and other
passenger ferries to make costly changes to the engines on their
vessels that are not feasible or purchase replacement vessels to
achieve reduced emissions, costing CCE upwards of $120
million. Without state funding to make this transition
feasible, the
current proposed regulations place an impossible financial burden
on CCE that is a privately regulated utility regulated by the CPUC.
The negative consequences of these new regulations, without
sufficient funding for the transition to new vessels equipped with
Tier IV engines, will negatively impact transportation efficiency,
reliability, and affordability.
These rules will not
only impact CCE and other passenger ferries, but could
significantly harm Catalina Island tourism and economic livelihood.
By providing adequate funding to help implement this transition,
the state can achieve its long-range emissions goals while
maintaining the vital ferry transportation system that serves the
people of Catalina and the workers and visitors that travel to the
Island.
STATE FUNDING IS CRITICAL
State funding is needed to
help private operators comply with the new regulatory mandates
being proposed. While CCE is committed to a longer-term goal of
eventually transitioning to zero-emission vessels, privately-owned
companies need time and adequate funding to achieve this
goal.
The cost to
repower an existing vessel is $7 million but will displace
approximately 50% of the passenger capacity. The cost to build a
new vessel is approximately $20 million. Compliance with Tier IV
mandated changes would cost upwards of $120 million to replicate
the same level of service with a fleet of new vessels. Without
dedicated state funding provided for this massive new expenditure,
these proposed regulations are far too cost prohibitive for a
privately owned company.
Without
increased and dedicated Carl Moyer funding or dedicated funding in
other CARB programs aimed at the new vessel purchases, these
mandates are simply not feasible because they are cost prohibitive
for a private company to finance.
LOSS OF RELIABLE AND
AFFORABLE FERRY SERVICE
Without sufficient funding provided by the state to make
this transition, these prohibitive costs would not only impact CCE
and the loss of reliable and affordable ferry service but would
significantly harm Catalina Island tourism and the economy. There
are no other viable options for passengers in large numbers to
reach the Island other than by ferry, so these costly and
economically harmful mandates to replace or upgrade ferries without
sufficient financial assistance to the operators will cause an
unavoidable ripple effect on every business and resident on the
Island.
In times like these, we should be
attracting visitors and supporting local economies, not
discouraging tourism, and fiscally harming small
communities.
On behalf of
more than 1,000 petition signatories, we strongly urge CARB to
prioritize funding for ferries like CCE for the Clean
Transportation Incentives program with sufficient funding to begin
to replace CCE’s fleet.
Thank you for
the opportunity to comment and for the thoughtful consideration of
the economic impacts these regulations will have on CCE, other
passenger ferries, and Catalina Island.
Sincerely,
Jim
Luttjohann
President & CEO
Love Catalina
jim@Lovecatalina.com
Comments
registered by petition signatories:
“The
economy on the island requires safe, regular and reliable ferry
service daily at a reasonable charge. The proposed carrier
requirements are too burdensome, expensive to implement, and will
hurt island residents, visitors and
businesses.”
“I
travel to Catalina often for leisure and business. This would cause
economic hardship on the people, business, and community of
Catalina. Catalina Express is the lifeline to the
island.”
“I am
signing as a property owner on Catalina Island, Avalon. Residents
have no other option for traveling from the island to mainland
Southern California. There are no roads or
bridges.”
“Convenient and affordable transportation is vital
to the wellbeing of the town of Avalon!”
“We own
property in Avalon and spend 3-4 months a year there, taking 5-6
round trips a year on the Express. Full-time residents have an even
greater need for affordable transportation across the channel.
Please provide state funding sufficient to make this feasible for
this special island.”
“We are
homeowners in Avalon and travel back and forth to the mainland
frequently. Catalina Express has always provided safe, affordable,
and reliable ferry transportation for our family. If CARB is
requiring expensive changes to the passenger ships, they should
have included financial assistance.”
Full
list of petition signatories attached.